IR 05000482/1987005
| ML20216G175 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/24/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| NUDOCS 8707010026 | |
| Download: ML20216G175 (2) | |
Text
I JUN 241987
In Reply Refer To:
Docket: STN 50-482/87-05
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Wolf Creek Nuclear Operating Corporation ATTN: Bart D. Withers President and Chief Executive Officer P. O. Box 411 Burlington, Kansas 66839 Gentlemen:
Thank you for your letter of June 12, 1987, in response to our letter and Notice of Violation dated May 15, 1987. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
Sincerely, i
K* @ n al siung y K. C. tm.'
J. E. Gagliardo, Chief Reactor Projects Branch cc:
Wolf Creek Nuclear Operating Corporation ATTN: Otto Maynard, Manager of Licensing P. O. Box 411 Burlington, Kansas 66839 Gary Boyer, Plant Manager Wolf Creek Nuclear Operating Corporation P. O. Box 411 Burlington, Kansas 66839 Forrest Rhodes, Vice President, Nuclear Operations Wolf Creek Nuclear Operating Corporation P. O. Box 411 Burlington, Kansas 66839 Kansas Radiation Control Program Director bec:
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NUCLEAR OPERATING CORPORATION Bart D. Withers President and chief Executrve officer June 12, 1987 pg -
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ATTN: Document Control Desk
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U. S. Nuclear Regulatory Commission 5.
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Washington, D. C.
20555 M i 51987 N --
y Letter: WM 87-0162 l
Re:
Docket No. 50-482 Ref:
Letter dated 5/15/87 from EHJohnson, NRC, to BDWithers, WCNOC Subj:
Response to Violations 482/8705-01 and 482/8705-02 Gentlemen:
Attached is a detailed response to violations 482/8705-01 and 482/8705-02
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which were documented in the Reference.
Violation 482/8705-01 concerns a failure to maintain the Total Plant Setpoint Document up-to-date. Violation 482/8705-02 concerns a failure to perform activities in accordance with established procedures.
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If you have any questions concerning this matter, please contact me or
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Mr. O. L. Maynard of my staff.
Very truly yours,
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J Bart D. Withers President and Chief Executive Officer BDW:jad
Attachment ec:
P0'Connor (2)
RMartin JCummins-1>
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P.O. Box 411/ Burlington KS 66839 / Phone: (316) 364-8831 An Equal opportunity Employer M.F/HC/ VET
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Attachment to WM 87-0162 Page 1 of 5 June 12,1987 i
Violation (482/8705-01): Failure to Maintain Total Setpoint Document (TPSD)
Up-to-Date
Finding:
Technical Specification (TS) 6.8.1 requires that, " Written procedures shall be established, implemented, and maintained covering.
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The applicable
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procedures recommended in Appendix A of RG 1.33, Revision 2, February 1978." Section 8 of Appendix A of RG 1.33 states that, " Specific procedures for... calibrations should be written (.
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calibration
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listed in the Technical Specifications)."
The licensee has established and implemented procedure ADM 05-103, Revision 2, "WCGS Total Setpoint Document" in accordance with TS 6.8.1, Section 5.2.1
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of ADM 05-103 states "The results engineering group will update and control j
the WCGS TPSD."
J Contrary to the above, a change request (No. AE 85-03) which had been issued and signed as being completed to update the feedwater flow transmitter calibration test data contained in the WCGS TPSD had not been made.
This
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resulted in using the incorrect test data to calibrate feedwater flow transmitters on or before January 14, 1987.
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Reason For Violation:
Failure to implement Total Plant Setpoint Document (TPSD) change request (No. AE 85-03),
feedwater flow transmitters calibration test data, was due to failure of the responsible Results Engineer to verify that the change to f
the TPSD was correctly entered by the Results Engineering clerk. Therefore,
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when the next revision to the TPSD was issued, change request No.
AE 85-03 was not incorporated.
On June 25, 1985, the change request was implemented by I&C and the feedwater flow transmitters were recalibrated.
However, since TPSD was not revised, I&C changed back to the incorrect data provided in the the TPSD on January 14, 1987 when the next recalibration was done.
This was corrected j
on February 4, 1987.
Corrective Steps Which Have Been Taken and Results Achieved:
In February 1986, the procedure for processing TPSD Change Requests was revised.
The Change Request is not incorporated into the TPSD until it has i
been returned from I&C as " implemented" with all necessary field work or recalibration completed. The Results Engineer reviews the TPSD Proof Sheets for the associated changes and verifies that the changes have been properly incorporated into the TPSD.
The Engineer then makes a Log Book Entry indicating that he has " proofed" the Change Request to provide the documentation that the computer data base has been properly updated, j
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Attachment to WM 87-0162 Page 2 of 5 June 12,1987 A review of all TPSD Change Requests from the initiation of the Change Request program in 1983 through May 1987 has been completed by Results Engineering. The results of this review are:
1.
Numerous editorial errors had been made in entering change request data into the TPSD database.
Misspelled words, incorrect digits in model numbers, and improper spacing were some of the common j
errors that were found.
None of these discrepancies affect I
calibration information.
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Errors were found involving improper calibration data for four instruments.
I&C calibrated three instruments correctly at the time it was issued for implementation.
No recalibration is necessary for these instruments.
However, one instrument was calibrated according to faulty information in the TPSD.
As it does not involve critical instrumentation, recalibration is scheduled during the refueling outage.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
The program revision described above provides verification of the incorporation of a TPSD revision into the computer database by Results Engin eering.
Additionally, the review of all TPSD change requests as
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described above verified that no other change requests affecting setpoints have been lost in the process of incorporation as was AE 85-03.
Additionally, the setpoint change request form that is used to initiate and j
track the status of changes to the TPSD has been revised to include a j
verification sign-o ff by the Results Engineer that all computer database changes have been completed.
As a result of the TPSD Change Request r eview and the resultant high degree of assurance that no other significant omission or inaccuracy in setpoint data currently exists in the TPSD, no further corrective steps are believed to be necessary, i
The Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
Comment The change request regarding tne feedwater flow transmitter calibration test data (No. AE 85-03) was signed as completed as it had been implemented in the field by I&C, and the flow transmitters recalibrated using the test data on the change request.
Subsequent issue of the next revision of the TPSD without change request No.
AE 85-03 caused I&C at the next recalibration to recalibrate using incorrect data.
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The results of the review performed by Results Engineering on all Change Requests from the initiation of the program in 1983 through May, 1987 provides a high degree of assurance that no omissions or inaccuracies in setpoint data currently exists in the TPSD which could cause errant indications on other critical instrumentation,..
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Attachment to WM 87-0162 Page 3 of 5 Jene 12,1987 Violation (482/8705-02): Failure to Perform Activities In Accordance with I
Established Procedures Finding:
Technical Specification (TS) 6.8.1 requires that,
" Written procedures shall be established, implemented, and maintained covering.
a.
The
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applicable procedures recommended in Appendix A of RG 1.33.
Revision 2, February 1978." Section 8 of Appendix A of RG 1.33 states that activities related to surveillance tests should be covered by written procedures.
Administrative Procedure ADM 02-300, Revision 8, " Surveillance Testing," and Surveillance Test STS RE-011, Revision 1,
"RCS Total Flow Rate Measurement" had been established and implemented in accordance with the above TS.
Section A.3 of ADM 02-300 defined test deficiency as "Any degraded condition associated with a surveillance activity which potentially results in the acceptance criteria not being met, premature termination of the surveillance, or any STS procedural discrepancies which require a procedure change."
Section 5.4.1.3 states that each test performer is responsible for documenting and reporting all test deficiencies to the shift supervisor, and
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Section 6.7.1 states:
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"Upon determination of a Test Deficiency, the Test Performer shall:
- Notify Shift Supervisor
- Document a brief description of the condition in the Test Deficiency section of the STRS.
(Section 3, Attachment 1)
- Initial and date in the Test Deficiency section of the STRS.
(Section 3, Attachment 1)."
Contrary to the above, during the performance of surveillance test STS RE-011, Revision 1,
"RCS lotal Flow Rate Measurement," on January 14, 1987, even though the total RCS flow rate calculated in accordance with STS RE-011 was below the minimum flow required by the STS and TS 3.2.3, the test performer did not, upon determination of this test deficiency, perform the activities required by Sections 5.4.1 3 and 6.7.1 of Administrative Procedure ADM 02-300, Revision 8, " Surveillance Testing."
Reason For Violation:
When the results of STS RE-011, RCS Total Flow Rate Measurement, indicated a reduction in RCS Flow Rate from cycle 1 of 3.6% (below the minimum flow rate required by Technical Specification 3/4.2 3),
the results were not considered to be indicative of actual plant conditions.
This information was immediately conveyed to the Plant Manager and the Superintendent of Operations.
The test was suspended and the following day the data was collected again to check repeatability, at which time the shift supervisor was informed that the results from the previous day were considered to be invalid.
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Attachment to WM 87-0162 Page'4 of 5 June 12,1987
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Plant Procedure ADM 02-300 defines test deficiency as "any degraded condition associated with a surveillance activity which potentially results'
in the acceptance criteria not being met, premature termination of the j
surveillance, or any STS procedural discrepancies which require a procedure i
change." At the time of the incident,.the test performer did not interpret j
the situation as constituting a test deficiency for the following reasons:
1.
Engineering judgement was that there was not a 3.6% reduction in flow rate from end of cycle 1 to beginning of cycle 2 and l
there were other plant indications to support this, therefore, the results were considered as invalid.
Had the results indicated a 3.6% increase in RCS flow rate with all other plant indications the same, the results would still have been considered as invalid.
At the time, the test performer did not consider invalid data as a basis for considering the potential of not meeting the acceptance' criteria to exist.
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The test was not terminated; It was suspended for investigation.
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There were no observed procedural discrepancies.
Corrective Steps Which Have Been Taken and Results Achieved:
ADM 02-300,
" Surveillance Testing", has been revised to further delineate required action in the event of a test deficiency.
The test performer and associated group have been advised that if a surveillance test result does not meet the acceptance criteria, it shall be handled as a test ' deficiency regardless of the circumstances, Corrective Steps Which Will Be Taken To Avoid Further Violations:
ADM 02-300,
" Surveillance Testing" has been revised to require that when a
surveillance test is suspended through shift. turnover due to a test deficiency, the NRC RRI also be notified -in addition to the shift supervisor.
Additionally, all groups performing surveillance procedures affecting operability have received instruction of the requirement and importance of notifying the shift supervisor of any test descrepancy or j
suspension.
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i The Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
Additional Comment Comments on the management decision to take the plant to an indicated power of 100% on January 19 and 20, 1987:
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Attachment to WM 87-0162 Page 5 of 5
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June la 1987
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It was the intent of Reactor Engineering to perform STS RE-011 at full power.
Instrument calibrations were being performed at 100% Reactor Thermal
Power (RTP) for performance of the surveillance when a plant trip occurred.
Due to.the calibration window of seven days as required by Technical Specification Surveillance Requirement 4.2.3.5, it was decided to per form the test during power-ascension at 76% RTP rather than repeat the entire calibration of associated instruments which had been completed. Step 2.1 of j
STS RE-011 states,
"This test should be conducted with the power level greater than or equal to 75% power to minimize instrument inaccuracies."
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R was known prior to performing the test at 76% power that inaccuracies were being introduced that would not be present at 100% RTP.
The test result indicated a 3.6% decrease in RCS flow rate which was determined to be' inaccurate.
Reactor power is directly proportional to the RCS flow rr.te, yet there were no indications of a similar drop in electrical output.
(1so, prior to increasing power to 100% RTP, calibration results of applicable instrumentation were checked.
The RCS flow rate measured at 100%'
RTP on January 19, 1987 was above the minimum required flow rate but still indicated a reduction from cycle 1.
At this point there was cause to suspect the calibration procedures of applicable instrumentation and power was maintained below 98% RTP pending the investigation and subsequent recalibration of feedwater flow instrumentation.
A review of other instrumentation necessary for the. RCS Flow and Calorimetric determinations has been completed.
STN-IC-417E " Calibration of Steam & Feedwater Flow Transmitters," STS-IC-504A " Reactor Coolant Flow -
Full Flow Calibration" and STS-IC-504B " Reactor Coolant Flow Transmitter
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Calibration" have been revised as necessary.
No other instrumentation or procedures required revision.
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